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Thomas M. Dater

Precision Unmanned Aerial Systems LLC

10606 W 35th Ct S

Wichita, KS 67215

(620) 245-7008

Tom.dater@Precision-UAS.com

www.Precision-UAS.com

August 18, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Submission of Request for Authorization to Conduct Unmanned Aircraft 

Systems Operations Allowed by Section 333 of the FAA Modernization and Reform 

Act of 2012 Through the Exemption Process Identified Under 14 C.F.R. Section 

11.81

Dear Sir/Madam,

Pursuant to Section 333 of PL 112-95 commonly known as the “FAA Modernization and 

Reform Act of 2012” or “The Reform Act”, Precision Unmanned Aerial Systems LLC

(d/b/a Precision UAS), hereby applies for authorization to conduct commercial 

unmanned aerial systems (UAS) operations for the agriculture, oil and gas and energy 

production, mining, structural mapping and inspection, landscape modeling, 

infrastructure management, surveying, aerial mapping and photography and videography, 

emergency and disaster response, forestry, humanitarian aid, conservation, and wildlife 

preservation industries, within the United States National Airspace System (NAS); within 

Class G and occasionally E airspace, along with additional restrictions identified herein. 

This request is separate from any and all Certificate of Authorization/Waiver (COA) 

requests submitted by public agencies identifying, Precision UAS (or its affiliates), as 

their UAS contract service provider authorized under Sec. 334 of the “Reform Act.” 

This request does not pertain to any and all activities conducted under the guidance of the 

Department of Defense while operating over restricted military airspace during military 

exercises in which, Precision UAS (or its affiliates), has been identified as a participant in 

providing UAS operations and support.
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Contained within is detailed information on why the approval of the request is in the 

“...public’s interest...” and how the approval will “...provide a level of safety at least 

equal to that provided by the rule...” Precision UAS seeks exemption from. In addition, 

through the vast operational experience in the UAS field seen nowhere within the civilian

community, Precision UAS will indicate how the approval will facilitate their ability to 

work with the FAA to “...safely accelerate the integration of civil unmanned aircraft 

systems into the national airspace system...” as directed by Congress.

Thank you for your time and consideration in this matter and please feel free to contact 

me with additional information or requests you may desire.

Thomas M. Dater

Precision UAS

Applicant Contact Information:

Precision Unmanned Aerial Systems LLC

Attn: Thomas M. Dater

10606 W 35th Ct S

Wichita, KS 67215

620-245-7008

tom.dater@precision-uas.com
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1. Company Background

2. Training & Operations

3. Regulations – Exceptions Requested

3.1. 14 C.F.R Part 21 Subpart H – Airworthiness Certificates

3.2. 14 C.F.R § 45.23 (b) – Aircraft Marking and Identification Requirements

3.3. 14 C.F.R § 91.7 (a) – Civil Aircraft Airworthiness

3.4. 14 C.F.R § 91.103 – Preflight Action

3.5. 14 C.F.R § 91.119 – Minimum Safe Altitudes

3.6. 14 C.F.R § 91.121 – Altimeter Settings

3.7. 14 C.F.R § 91.151 (a) – Fuel Requirements for Flight in VFR Conditions

3.8. 14 C.F.R § 91.405 (a)(1), § 91.409 (a)(2), and § 91.417 (a) & (b) –

Maintenance Inspections

4. Public Interest

5. Privacy Concerns

6. FAA Collaboration

7. Summary ~ Federal Registry

Appendix!A

Additional Documents

• Flight Planning Document 

• Precision UAS Operations Manual
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1. Company Background

Precision Unmanned Aerial Systems LLC was conceptualized in 2014 when the founder 

noted that nearly every industry could benefit from the use of Unmanned Aerial Systems 

(UAS). Precision Unmanned Aerial Systems LLC was founded in 2015 as a realization of 

this concept. Drawing from over a decade of experience and 10,000+ hours of operational 

experience in the UAS industry and 1,000+ hours commanding missions aboard a 

manned Intelligence Surveillance and Reconnaissance (ISR) aircraft. Conducting 

missions in congested airspace during operational missions sets both state side and 

forward deployed in support of Operations Enduring Freedom, Iraqi Freedom, New 

Dawn, and Resolute Support along with other real world contingencies and exercises; 

Precision UAS has a resume of UAS operational experience that is unparalleled.

In addition, the founder of Precision UAS has spend the last four years as a Systems 

Engineer supporting ISR operations in Afghanistan by performing sensor, 

communication, and aircraft maintenance providing invaluable experience. The 

experience and diversity that Precision UAS brings to the United States civilian UAS 

operations industry is second to none and is therefore “... in the public’s best interest...” 

for the Secretary to approve this exemption request.

2. Training & Operations

Section 333 of “The Reform Act” states:

“...the Secretary of Transportation shall determine if certain unmanned aircraft 

systems may operate safely in the national airspace system...In making the 

determination under subsection (a), the Secretary shall determine, at a 

minimum— (1) which types of unmanned aircraft systems, if any, as a result of 

their size, weight, speed, operational capability, proximity to airports and 

populated areas, and operation within visual line of sight do not create a hazard 

to users of the national airspace system or the public or pose a threat to national 

security...”

Precision UAS will adhere to the specifications and requirements set within their 

operations manual(s), Operations manual(s) of aircraft listed in Appendix A and FAA 

guidelines to include but not limited too; 8900.1 CHG 351 Volume 16, 8900.227 and 

more specifically the requirements set within the Section 333 exemption approval # 

11062, recently obtained by Astraeus Aerial.

Precision UAS seeks authorization to utilize the systems listed in Appendix A to conduct 

operations for agriculture, oil and gas and energy production, mining, structural mapping 

and inspection, landscape modeling, infrastructure management, surveying, aerial 

mapping and photography and videography, emergency and disaster response, forestry, 

humanitarian aid, conservation, and wildlife preservation industries. We fully anticipate 

conducting operations for two or more industries concurrently over the same area and 

therefore believe, flight operations and the safety of, require our full attention regardless 

of whether the aircraft is imaging a piece of land or collecting informational data at the 
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same location. The fixed wing and multi-rotor aircraft selected by Precision UAS all meet 

the requirements for determination by being less than 55 pounds (all systems weighing 

under 15 pounds), flying at speeds under 60 knots, and flying for less than two hours 

(battery limited). Operating within visual line of sight (VLOS) and remaining below 400 

ft AGL are standard operating procedures for Precision UAS and will remain so until 

further advances in safety of flight are introduced to the market and regulated by the 

FAA. As described below, all operations will be confined to those areas no closer than 

one statue mile of any airfield and the proper authorities will be notified with any 

operations within five statue miles. Furthermore, when it comes to national security 

concerns, Precision UASs’ founder has spent 10+ years defending our country as a 

military member ensuring national security is of the utmost priority in any activities they 

partake in.

Operator Training: All PIC and Supplemental Pilots (SP) will abide by the requirements 

set forth in 8900.1 CHG 351 Volume 16. All initial aircraft flight operations and 

maintenance training will be conducted by a certified flight/maintenance instructor. Once 

an operator is certified they will they will enter into Precision UAS operations 

qualification training which includes FAA authorized ground school training and a thirdclass medical examination. Upon successful completion, the operator will earn their

Supplemental Pilot(SP)/Visual Observer (VO) rating. SP/VO will be required to conduct 

25 operational hours to be considered for PIC qualification testing in addition to holding 

at a minimum, private pilot license. The operator will then be required to complete a 

written test and “check ride” in which upon successful completion, the operator will 

receive their PIC rating.

NOTE: Ground School Training will be conducted by FAA certified instructors

Initial certification training requirements include:

Pre-Flight Training:

• Unpacking and assembly

• Power requirements, set-up and connectivity

• System end-to-end set-up and test / inspections

• Preflight, run-up and system checks

Flight Operations Training:

• Proper Handling

• Motor Operations

• GCS Flight Programming and Test

• Launch

• Basic Flight (climb, cruise, descent, landing)

• Maneuvering

• Airspace and Landing Zone Operations

• Flight Reprogramming

• Flight Monitoring

• In-Flight Emergency Procedures
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Post Flight:

• Shut Down Procedures

• Data Retrieval and Storage

• End-to-End Test and Maintenance Logs

• Disassembly

• Packing, Storage and Transportation

SP/VO qualification training requirements instructed by Precision UAS include:

• Understanding FAA Rules / Regulations

• Collection Requirements

• Operational Planning

• Flight Planning

• Area of Operations ~ Hazard Mitigation

• Daily Flight and Inspection Log Completion

• Proper Authority Notification Process

• Crew Resource Management (CRM)

PIC qualification testing requirements instructed by Precision UAS include:

• Written Exam consisting of 60 questions with a pass rate of 70% following the 

guidelines set forth by the FAA Airman Knowledge Testing requirements

• “Check Ride” and Oral exam consisting of:

o Airport Operations

o Maintenance Inspections

o Flight Plan Development

o Area of Operations Hazard Mitigation

o Weather Hazard Mitigation

o Emergency Procedures

o Pre-Flight Operations

o Flight Operations

o Post-Flight Operations

Operations Execution: Given the fact commercial UAS operations are restricted due to 

the lack of regulations, a logical and safe solution is to utilize the safety guidance 

provided for hobbyist use of sUAS and other model aircraft as identified by Advisory 

Circular 91-57 and Section 336 of the “Reform Act”. Precision UAS operations will be 

conducted in a methodical, efficient, and most importantly safe manner adhering to strict 

guidelines that address safety concerns with proximity to airports and populated areas in 

the interim of official guidance from the FAA as the rules and regulations are being 

further developed.

The following list provides specific rules and guidelines all Precision UAS operations 

will adhere to too ensure at least an equivalent or higher level of safety when compared to 

manned aircraft performing the same functions as outlined within 14 C.F.R.

1) All flight crews will:
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• Be comprised of a minimum of two certified operators; one serving as PIC 

and the others as VO

• Consist of one certified air vehicle maintenance technician to conduct pre 

and post flight inspections

NOTE: PIC/SP/VO may also fill the role of the maintenance technician

• Attend pre and post flight mission briefs which will consist of weather 

information, flight information to include operational area and mission 

objectives, hazard mitigation actions and most importantly emergency and 

abort procedures; also included will be any NOTAMs or improvements to 

standard operating procedures through further refinements in operations

• Sign applicable documentation verifying their attendance to mandatory 

briefs as well as produce daily pre and post flight inspections and flight 

logs

• Communicate over two way radio, cell phone and/or other communication 

devices identified to increase operational efficiencies

2) All flight operations will:

• At no time fly within one statute mile of any operational airfield

• Provide prior notification to airfield operator and airfield air traffic control 

tower (when applicable) when operating within five statute miles of any 

active airfield; no later than 24 hours prior to air operations

• Provide prior written notification to FSDO(s) and local/county sheriff and 

fire departments in the event assistance is required to include: flight plans, 

type and capabilities of air vehicle(s) operated and operator’s contact 

information; no later than 72 hours prior to operations

• Be conducted using sUAS as defined by the FAA weighing less than 55 

lbs; all operations authorized through this exemption request will be done 

with the aircraft listed in Appendix A (future aircraft will be presented to 

FAA for approval prior to operational use)

• Be conducted in Class G and occasionally E airspace and shall not exceed 

400 ft above ground level (AGL)

• Be conducted within visual line of sight (VLOS) of the qualified PIC and 

VO

• Give right-of-way to and avoid flying near manned aircraft at all times

• Be conducted in rural environments and outside of city limits

• Be conducted with prior written consent from land owner

• Ensure air vehicles do not encroach within 250 ft of any improved road, 

person, vehicle or structure that is not associated with operations

• Abort/Cancel in the event of detrimental weather to include wind speeds 

exceeding the allowable limits as defined within operations manual

3) Emergency Procedures: All emergency procedures will be conducted within 

the guidelines outlined within the aircrafts operations manual to include but not limited to 

the following: 
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• In the event the air vehicle losses GPS signal, automated return to home will 

immediately commence based on the pre-programmed parameters identified and 

uploaded prior to initiation of flight. The flight plan is built in such a way that 

hazards are identified prior to launch will allow the PIC to successfully recover 

control of the air vehicle.

• In the event the PIC losses signal with the air vehicle, automated return-to-home 

and loiter will commence until signal is regained. The flight plan is built in such a 

way that all hazards are identified prior to launch and an automated landing in the 

event signal is not regained will be conducted in a safe and responsible manner.

• In the event hazardous weather unexpectedly approaches and may affect 

operations, the PIC will immediately abort the operation and conduct landing 

activities

• In the event an in-flight emergency occurs, (i.e. air vehicle maintenance issues), 

the PIC will immediately abort flight and conduct landing activities; air vehicle 

inspection will immediately be achieved and the air vehicle will not return to 

service without proper authorization from certified maintenance technicians

• In a “significant” event (i.e. air vehicle crashes and outside assistance is needed), 

PIC will conduct notification procedures to include county sheriff and fire 

departments, airfield operator/tower if applicable and any other authority required 

to mitigate situation

o A “significant” event report will be generated by the PIC, verified by the 

VO and maintenance technician and immediately provided to the Director 

of Operations

NOTE: Notification will be made to the FAA to assist in future prevention techniques

By following these strict, mostly self imposed guidelines; Precision UAS, will achieve a 

safety level greater than that directed by the rules in which they seek exemption, 

especially true when you compare the same operating procedures against a manned 

aircraft. SUAS are inherently safer in all facets due to the fact that they are much smaller, 

fly at much lower speeds, there are no human operators on board and there is zero fuel to 

be concerned with in the event of a crash. As processes are further refined, the operations 

will only add to an already higher level of safety compared to manned flight operations in 

which serves the public’s best interest in the FAA’s endeavor to integrate UAS into the 

NAS.

3. Regulation – Exemption Requested

Pursuant to 14 C.F.R. § 11.81(e), Precision UAS seeks exemption from the below 

mentioned regulations and provides reason as to why the exemption should be approved 

based on the level of safety at least equal to that of which the rules require.

3.1

• 14 C.F.R. Part 21 Subpart H – Airworthiness Certificates

! Establishes: The procedural requirements for the issuance of airworthiness 

certificates as required by 14 C.F.R. § 91.203(a)(1)
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Given the small size of the UAS, the limited operating areas and meticulous procedures 

defined within the training and operations section (re-iterated below), an exemption from 

Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 

and Section 333 of the “Reform Act” with consideration “of the size, weight, speed, 

operational capability, and proximity to airports and populated areas of the particular 

UAS.”

• No operations within one statute mile; Prior notice given to ATC 

tower/Airport Operator w/in five statute miles

• Operations only directly over working area within city limits; Rural areas only 

with a minimum distance of 250 ft from persons, structures, roads and 

vehicles

3.2

•14 C.F.R. § 45.23(b) – Aircraft Marking and Identification Requirements

! 14 C.F.R. § 45.23(b), Markings of the Aircraft, states:

When marks include only the Roman capital letter "N" and the registration 

number is displayed on limited, restricted or light-sport category aircraft or 

experimental or provisionally certificated aircraft, the operator must also display 

on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters 

not less than 2 inches nor more than 6 inches high, the words "limited," 

"restricted," "light-sport, "experimental," or "provisional," as applicable.

Precision UAS will ensure compliance with § 45.29(f) to meet the intent of the regulation 

by placing the word “experimental” on the fuselage of the air vehicle(s).

NOTE: The FAA has set precedence to this regulation within like given parameters and 

an exemption should be approved on this basis along with previous exemptions: Nos. 

10700, 10167 and 10167A. Also, see most recent exemption approvals for Blue-Chip 

UAS, Astraeus Aerial, Aerial MOB, HeliVideo Productions, RC Pro Productions, 

Snaproll Media and Pictorvision for further justification of approval.

3.3

• 14 C.F.R. 91.7(a) – Civil Aircraft Airworthiness

! States: No person may operate a civil aircraft unless it is in an airworthy 

condition.

Section 333 of the Modernization Act authorizes the FAA to exempt aircraft from the

requirement for an airworthiness certificate based on a consideration of the size, weight, 

speed, operational capability of the particular UAS, as well as its proximity to airports 

and populated areas. An analysis of these criteria demonstrates that the sUAS operated 

without an airworthiness certificate in the areas and under the conditions contemplated by 

Precision UAS will be at least as safe, or safer, than a conventional aircraft (fixed wing or 
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rotorcraft) operating with an airworthiness certificate without the conditions proposed in 

this request. 

The sUAS listed in Appendix A weigh less than 55 lbs. fully loaded, carry neither a pilot 

nor passenger, and operate under tight control restrictions. Unlike other civil aircraft, 

operations under this exemption will be tightly controlled and monitored by the PIC and 

VO. Operations will be conducted in compliance with the FAA and with local public 

safety requirements to provide security for the area of operation. These safety 

enhancements provide an expanded degree of safety over conventional aircraft 

operations. Lastly, application of these same criteria demonstrates that there is no 

credible threat to national security posed by the sUAS, due to its size, speed of operation, 

location of operation, lack of explosive materials (fuel and/or flammable liquids) and 

inability to carry a substantial external load.

Given the size and limited operating area associated with the aircraft to be utilized by the 

Applicant, this meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and 

Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificate, upon consideration of the size, weight, 

speed, operational capability, and proximity to airports and populated areas of the 

particular sUAS. In all cases, an analysis of these criteria demonstrates that the UAS 

operated without an airworthiness certificate, in the restricted environment and under the 

conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed 

wing or rotorcraft) operating with an airworthiness certificate without the restrictions and 

conditions proposed.

NOTE: The FAA has set precedent by previously issuing exemptions for § 91.7(a): 

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 

32827, and 10700. Also, see most recent exemption approvals for Blue-Chip UAS, 

Astraeus Aerial, Aerial MOB, HeliVideo Productions, RC Pro Productions, Snaproll 

Media and Pictorvision for further justification of approval.

3.4

• 14 C.F.R. 91.103 – Preflight Action

! States: Each pilot in command shall, before beginning a flight, become familiar 

with all available information concerning that flight. This information must 

include- (paragraphs a, b, 1 and 2)

A pre-flight mission brief must be attended by all crewmembers. This “PMB” will 

contain weather and all flight information including emergency and abort procedures. A 

signature will be required by all crew members indicating they have received the PMB 

and have read any NOTAMs or other procedural updates which may have impact to 

standard operating procedures. In addition, the PIC will verify air vehicle is ready for 

flight by coordinating with the maintenance technician during pre-flight inspection.
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The exemption requested for this section is specifically addressed toward the 

requirements that do not apply to sUAS operations such as runways and air traffic control 

integration.

NOTE: As previously stated, air traffic control and airport operator will be notified prior 

to any operations being executed within five statute miles

NOTE: The FAA has recently set precedence to this regulation within like given 

parameters and an exemption should be approved on this basis. See exemption approvals 

for Blue-Chip UAS, Astraeus Aerial, Aerial MOB, HeliVideo Productions, RC Pro 

Productions, Snaproll Media and Pictorvision.

3.5

• 14 C.F.R. 91.119 (c) – Minimum Safe Altitudes

! States: Except when necessary for takeoff or landing, no person may operate an 

aircraft below the following altitudes: (c) Over other than congested areas. An 

altitude of 500 feet above the surface, except over open water or sparsely 

populated areas. In those cases, the aircraft may not be operated closer than 500 

feet to any person, vessel, vehicle, or structure.

All Precision UAS operations will be conducted at 400 ft AGL or below in uncontrolled 

Class G and occasionally E airspace. As sUAS are inherently safer than traditional 

aircraft due to their small size, lightweight, battery operated versus fuel and no human 

on-board; Precision UAS will not operate within 250 ft to any improved roads, vehicles 

persons or structures (other than those being inspected as part of the flight operation). In 

addition, objects/hazards will be identified and geo-located prior to flight to be utilized 

within the flight planning stages to ensure this objective is met.

3.6

• 14 C.F.R. 91.151(a) – Fuel Requirements for Flight in VFR Conditions

! States: No person may begin a flight in an airplane under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to 

the first point of intended landing and, assuming normal cruising speed— (1)

During the day, to fly after that for at least 30 minutes;

This regulation is written based on the capabilities of a traditional aircraft which have 

flight times of several hours or greater; therefore, with the majority of sUAS which have 

flight times of only an hour or less, this regulation would effectively deny the ability of 

the air vehicle to operate.

Using a Cessna 182 as an example, approximately 8% remaining fuel is required to meet 

the 30 minute flight time directed by this regulation. To meet the intent, Precision UAS, 

will operate its air vehicles to no less than 10% remaining battery power to ensure safe 

landing and retrieval of the air vehicle. This 10% buffer is greater than the Cessna 182 
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and the ability to quickly and safely land sUAS in non-traditional environments ensures 

at least an equal level of safety.

NOTE: The FAA has set precedent by previously issuing exemptions for § 91.151(a): 

Exemption Nos. 10673, 2689F, 5745, 10673 and 10808. Also, see most recent exemption 

approvals for Blue-Chip UAS, Astraeus Aerial, Aerial MOB, HeliVideo Productions, RC 

Pro Productions, Snaproll Media and Pictorvision for further justification of approval.

3.7

• 14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b) – Maintenance 

Inspections

! 91.405(a) States: Each owner or operator of an aircraft—(a) Shall have that 

aircraft inspected as prescribed in subpart E of this part and shall between 

required inspections, except as provided in paragraph (c) of this section, have 

discrepancies repaired as prescribed in part 43 of this chapter

! 91.407(a)(1) States: (a) No person may operate any aircraft that has undergone 

maintenance, preventive maintenance, rebuilding, or alteration unless—(1) It has 

been approved for return to service by a person authorized under § 43.7 of this 

chapter

! 91.409(a)(2) States: (a) Except as provided in paragraph (c) of this section, no 

person may operate an aircraft unless, within the preceding 12 calendar months, it 

has had—(2) An inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter. No inspection performed under paragraph 

(b) of this section may be substituted for any inspection required by this 

paragraph unless it is performed by a person authorized to perform annual 

inspections and is entered as an ‘‘annual’’ inspection in the required maintenance 

records.

! 91.417(a) & (b) States: (a) Except for work performed in accordance with §§ 

91.411 and 91.413, each registered owner or operator shall keep the following 

records for the periods specified in paragraph (b) of this section: (paragraphs 1 (i 

– iii), 2 (i – vi)); (b) The owner or operator shall retain the following records for 

the periods prescribed: (paragraphs 1 – 3)

Pre/Post and routine inspections (not to exceed 50 flight hours) and maintenance will be 

conducted in accordance with the manufacturer’s guidance. In addition, to meet the intent of 

these regulations, Precision UAS, will maintain daily logs of pre and post flight inspections 

and have maintenance performed by certified technicians and/or the manufacturer 

themselves. In the event maintenance is required, certified technicians will verify the air 

vehicle is in flight readiness status prior to releasing to PIC for use in operations. 

Unscheduled maintenance will be accomplished in the event of a mechanical or structural 

failure during flight. Upon completion of unscheduled maintenance, documentation will be 

provided to the Director of Operations to sign off and verify that the air vehicle is once again 

ready for flight and accept the level of risk associated with returning the air vehicle to flight 
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status. At no time will there be changes made to the air vehicle that would impact the 

structural integrity of the airframe without the manufacturer making such changes and 

verifying the flight its airworthiness. 

All inspection and maintenance will be documented and maintained in-house. These actions 

will meet the intent of the regulation exemption is being requested and lead to the equivalent 

level of safety. 

NOTE: The FAA has recently set precedence to this regulation within like given 

parameters and an exemption should be approved on this basis. See exemption approvals 

for Blue-Chip UAS, Astraeus Aerial, Aerial MOB, HeliVideo Productions, RC Pro 

Productions, Snaproll Media and Pictorvision.

4. Public Interest

The public’s best interest is achieved by the safe integration of UAS into the NAS. With 

the ongoing exemption process, the FAA has to identify those exemption requests with 

the public’s best interest in mind and select the companies who will be able to achieve 

this in a safe and responsible manner. Two of the main problems the public has with UAS 

are the fear of what they will be used for and whether or not they are safe to fly within the 

same airspace as commercial airliners. Precision UAS is more than willing to help with 

public education and that starts with conducting operations within strict operating 

environments and then providing the results to the public to start to sway opinion in a 

positive light.

With the experience this team has built from UAS operations, manned flight operations 

and training and aircraft maintenance; the FAA will provide a great service to the 

American public by approving Precision UASs’ exemption request herein. Precision

UAS will provide any additional information requested and will diligently work with the 

FAA to make this approval a reality as it is in the best interest and safety of the public as 

directed by Congress.

5. Privacy Concerns

As previously stated, one of the main concerns the public has with the integration of UAS 

into the NAS is privacy and spying; especially as of recent with the “disclosure” of the 

NSA’s communication programs. The media has also placed a negative light on UAS 

when it comes to privacy; showing only how the military has used this technology to 

conduct combat operations through the use of the visual and infrared sensors they carry.

Fortunately with this matter, Precision UAS is well versed in the privacy and oversight 

concerns which are addressed by federal government regulations: Executive Order 

12333, DoD Directive 5240.1-R and AFI 14-104. Although the regulations do not apply 

to private commercial entities, our knowledge and experience in working within these 

regulations will assist and ensure any and all privacy concerns will be minimal and 

immediately mitigated.
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In addition, the most efficient and successful avenue to combat these concerns is to 

educate the public in how UAS technology will be used to exponentially improve all of 

our lives as Americans and place emphasize on how we should embrace the technology 

instead of fearing it. In these regards, Precision UAS will look at actions we can take to 

move forward with this endeavor and assist the FAA and all UAS employment 

companies as a whole to better public perception and create a cohesive environment we 

all can operate in safely.

6. FAA Collaboration

Precision UAS is committed to the safe integration of UAS into the NAS and will 

provide any and all information on its flight operations to the FAA to assist in the rules 

making process. As stated in the operations section, post flight logs will be required to be 

completed to produce monthly flight summaries which will include both positive and 

negative reporting placing emphasize on any issues which may arise during any segment 

of the operations. Precision UAS offers the monthly summaries to the FAA as input and 

flight data to ensure accurate information is utilized along with offering our expertise and 

knowledge in the rule making process.

7. Summary ~ Federal Register

Pursuant to Section 333 of PL 112-95 commonly known as the “FAA Modernization and 

Reform Act of 2012” or “The Reform Act”, Precision Unmanned Aerial Systems LLC

(d/b/a Precision UAS), hereby applies for authorization to conduct commercial unmanned 

aerial systems (UAS) operations for agriculture, oil and gas and energy production, 

mining, structural mapping and inspection, landscape modeling, infrastructure 

management, surveying, aerial mapping and photography and videography, emergency 

and disaster response, forestry, humanitarian aid, conservation, and wildlife preservation 

industries, within the United States National Airspace System (NAS); within Class G and 

occasionally E airspace.

Rules in which Precision UAS seeks exemption:

• 14 C.F.R. Part 21 Subpart H

• 14 C.F.R. § 45.23(b)

• 14 C.F.R. § 91.7(a)

• 14 C.F.R. § 91.103

• 14 C.F.R. § 91.119

• 14 C.F.R. § 91.151(a)

• 14 C.F.R. § 91.405(a)

• 14 C.F.R. § 91.407(a)(1)

• 14 C.F.R. § 91.409(a)(2)

• 14 C.F.R. § 91.417(a) & (b)

Throughout this exemption request, Precision UAS has shown how their expertise and 

knowledge with UAS technology will ensure the public’s best interest is at hand and 

assist the FAA with their charge to: “...safely accelerate the integration of civil 
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unmanned aircraft systems into the national airspace system...” as directed by Congress. 

They have also shown how the approval of this request will meet and exceed “...at least 

an equivalent level of safety...” for the regulations they seek exemption.

At each level through process refinement, Precision UAS will capture and document the 

best practices to develop proven tactics, techniques and procedures and provide that 

information to the FAA to incorporate into the UAS integration process.

When it comes to the public and what is in their best interest you will be hard pressed to 

find a team more qualified for an exemption under Section 333 than Precision UAS. It 

will be a great service to the country and in the “public’s best interest” to include this 

team in the UAS integration endeavor in which an equivalent level of safety will be 

ensured by operations being conducted by the undisputed experts they are.
Page!16 of!23

Appendix A

Specific sUAS Types, Make, and Model

Fixed Wing

#1 SenseFly eBee

See Attached:

eBee User Manual V16

#2 Precision Hawk Lancaster

See Attached:

2015 Lancaster tech specs

Additional Information:

The FAA has set precedent by previously issuing exemptions for this aircraft: Exemption 

No. 11172
Page!17 of!23

#3 Quest Q-200

See Attached:

Manufacturer did not provide documentation at time of request. 

#4 HoneyComb Ag Drone

Additional Information:

The FAA has set precedent by previously issuing exemptions for this aircraft: Exemption 

No. 11223
Page!18 of!23

#5 C Astral Bramor

See Attached:

Manufacturer did not provide documentation at time of request. 

#6 Swift Radioplanes Lynx

See Attached:

Lynx User Manual 2-5
Page!19 of!23

#7 AgEagle

See Attached:

Manufacturer did not provide documentation at time of request. 

#8 Skywalker X-8

Additional Information:

The FAA has set precedent by previously issuing exemptions for this aircraft: Exemption 

No. 11172
Page!20 of!23

#9 Marcus UAV INC Zephyr 2

See Attached:

Manufacturer did not provide documentation at time of request. 
Page!21 of!23

Multirotor

#1 SenseFly eXom

Additional Information:

The FAA has set precedent by previously issuing exemptions for this aircraft: Exemption 

No. 11263A

#2 DJI Inspire

See Attachments:

DJI Inspire User Manual V1.4

DJI Inspire Maintenance Manual V1.0

DJI Inspire Safety Guidelines
Page!22 of!23

#3 DJI Phantom 3 Professional

See Attached:

DJI Phantom 3 Professional User Manual V1.4

DJI Phantom 3 Safety Guidelines

#4 DJI S1000+

See Attached:

DJI S1000+ User Manual
Page!23 of!23

#5 Altus X8

Additional Information:

The FAA has set precedent by previously issuing exemptions for this aircraft: Exemption 

No. 11172

#6 3DR X8+/M

See Attached:

X8 Checklist VB

X8 Operations Manual VC

Additional Information:

The FAA has set precedent by previously issuing exemptions for this aircraft: Exemption 

No. 11172